https://www.taxtmi.com/acts?id=5537 Article 5 defines permanent establishment as a fixed place of business, enumerates examples (place of management, branch, office, factory, workshop, sales outlet, warehouse providing storage for others, agricultural or resource extraction sites), and treats construction or assembly projects as permanent establishments only if lasting more than six months. It excludes activities of a preparatory or auxiliary character (storage, display, delivery, stock for processing, purchasing, information collection) and sets out agency rules: dependent agents who habitually conclude contracts, maintain stock for delivery, or secure orders can create a permanent establishment, whereas independent agents acting in the ordinary course do not, unless devoted almost wholly to one enterprise; insurance premium collection through non independent persons also creates a permanent establishment. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 18 Nov 2024 16:54:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5537 Article 5 defines permanent establishment as a fixed place of business, enumerates examples (place of management, branch, office, factory, workshop, sales outlet, warehouse providing storage for others, agricultural or resource extraction sites), and treats construction or assembly projects as permanent establishments only if lasting more than six months. It excludes activities of a preparatory or auxiliary character (storage, display, delivery, stock for processing, purchasing, information collection) and sets out agency rules: dependent agents who habitually conclude contracts, maintain stock for delivery, or secure orders can create a permanent establishment, whereas independent agents acting in the ordinary course do not, unless devoted almost wholly to one enterprise; insurance premium collection through non independent persons also creates a permanent establishment. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5537